A ban on products made with forced labour.
Any product made wholly or partly with forced labour, at any stage of its supply chain and from any country of origin, cannot be placed on the EU market, made available on it, or exported from it.
European Union; applies to imports and exports
Product prohibition
In force; preparation period
14 December 2027
The essentials
At a glance
The questions in-scope teams tend to ask first: does this apply to us, how far it reaches, and what happens if we do not comply?
For responsible sourcing and compliance
What EUFLR means for your assessment programme
Most due diligence regulation asks whether a company followed the right process, and you choose when to show your work. EUFLR asks whether one specific product is affected, and you do not choose when that question arrives. From 14 December 2027, anyone can submit information about a company or a product through a single EU submission point, including anonymously. An authority then decides whether to open an investigation.
If an authority opens an investigation, it will ask for information about a specific product and its suppliers, and give you 30 to 60 working days to provide it. That is not enough time to arrange a site assessment, trace a material back to where it was grown or mined, or finish a corrective action. Whatever you can show is whatever you already had.
So the question is what your supplier programme produces as a matter of routine: who your suppliers are and where their sites are, what working conditions were found there, and what was done about anything the assessment picked up. Procurement feels this too, because the response to a finding is a supplier conversation.
The prohibition
What EUFLR asks of you
EUFLR does not require you to carry out due diligence. It prohibits products made with forced labour from reaching the EU market. Doing due diligence well does not protect the product if forced labour is found. What it does is make the finding less likely, and put you in a better position if an investigation opens.
What is prohibited
Article 3 sets out a single prohibition. No product made wholly or partly with forced labour may be placed on the EU market, made available on it, or exported from it. The Regulation uses the ILO Convention No 29 definition: work exacted under coercion, which the person has not offered to perform voluntarily. Both involuntariness and coercion must be present. The Regulation distinguishes three forms: privately imposed forced labour, state-imposed forced labour and forced child labour. It treats the state-imposed form as inherently large-scale and severe.
In an investigation
How a case unfolds
The Regulation sets out the process below. It starts operating on 14 December 2027, and no investigations can be opened before then.
Investigations are led by a competent authority: a Member State authority where the suspected forced labour is on its territory, the European Commission where it is outside the EU.
Cases are prioritised by how serious and widespread the suspected forced labour is, how much of the affected product is on the EU market, and how significant the affected part is within the finished product. In deciding which companies to pursue, authorities then look at how close a company is to the forced labour, how much influence it has, its size and resources, and how complex its supply chain is.
Key dates
The road to application
The Regulation has been in force since the end of 2024. The prohibition starts applying in December 2027, with the preparation period running in between.
Contact
Understand your exposure under EUFLR
Talk to our team about what the prohibition means for your supply base, and about the evidence you would need to produce.
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